Case Summary (G.R. No. 264439)
Factual Background
Ramon O. Sampana filed a complaint against TMTCP and its executives, alleging illegal dismissal, regularization, and payment of retirement benefits, among other claims. Sampana was initially hired under a consultancy agreement in 2011, which was continuously renewed every three months until 2014, at which point it was transformed into a fixed-term employment contract. He continued working under successive contracts until his dismissal in December 2016, at which time he had expressed his intent to retire after fulfilling requisite employment duration, having served over five years.
Dispute Over Employment Status
TMTCP contended that Sampana's employment was on a fixed-term basis, refuting claims of illegal dismissal. The company argued that due to complaints about Sampana’s teaching methods, they opted not to renew his contract after its expiration. TMTCP further maintained that his consultancy period should not count towards the five-year requirement for retirement benefits, as no employer-employee relationship existed during that time.
Labor Arbiter's Ruling
On August 31, 2017, the labor arbiter ruled in favor of Sampana, recognizing him as a regular employee entitled to retirement benefits, having served for five years. However, the arbiter found no illegal dismissal, claiming that Sampana voluntarily chose to retire.
National Labor Relations Commission (NLRC) Decision
Upon TMTCP's partial appeal, the NLRC reversed the labor arbiter’s decision on June 26, 2018, ruling that Sampana was merely a fixed-term employee. It stated that the consultancy period should be excluded from the employment computation for retirement benefits, leading to the conclusion that he had not met the five-year service requirement.
Court of Appeals Ruling
The Court of Appeals upheld the NLRC's decision on March 18, 2021, reaffirming that Sampana’s employment was fixed-term and that he did not meet the requisite service duration for optional retirement. His subsequent motion for reconsideration was denied on October 20, 2022.
Current Petition to the Supreme Court
Sampana contended before the Supreme Court that he was a regular employee and had been unjustly dismissed. He argued that the contractual nature of his employment was crafted to circumvent his right to security of tenure, inhibiting him from achieving regular employee status.
Supreme Court's Analysis on Employment Status
The Supreme Court recognized that the NLRC's findings on the nature of Sampana’s employment required reassessment, especially given the apparent disharmony between the NLRC and labor arbiter’s decisions. It evaluated whether the necessary employer-employee relationship existed, employing the four-fold test for establishing such a relationship.
Judicial Findings
The Supreme Court ultimately concluded that Sampana had been a regular employee from March 21, 2011, until his termination on December 21, 2016. It determined that the nature of his employment, despite being labelled as "consultancy," effectively constituted a scheme to deny him security of tenure. The Court declared that TMTCP's fixed-term contracts did not withstand scrutiny and were contrary to the Labor Code provisions aimed at protecting employee rights.
Ruling on Dismissal
Recognizing Sampana as a regular employee entitled to security of tenure, the Supreme Court held that his dismissal was illegal, give
...continue readingCase Syllabus (G.R. No. 264439)
Background and Parties Involved
- Ramon O. Sampana (Petitioner) filed a complaint against The Maritime Training Center of the Philippines (TMTCP), its CEO Captain Alejandro C. Aquino, Jr., and Administrative and Finance Manager Normandy E. Gualberto (Respondents).
- Sampana was initially hired as an Instructor under a consultancy agreement from March 21, 2011 to June 21, 2011, with successive renewals until March 20, 2014.
- Later, his contract was changed to "Employment with a Fixed Term" for periods of three months at a time from March 21, 2014 to December 21, 2016.
- Sampana sought illegal dismissal, regularization, retirement benefits, 14th month pay, training fees, separation pay, damages, and attorney's fees.
Factual Antecedents
- Sampana claimed continuous employment exceeding five years and turned 60 years old, requesting retirement benefits.
- He was allegedly dismissed effective December 21, 2016 and required to sign a clearance form releasing claims.
- TMTCP argued Sampana was a consultant until March 2014, later engaged on valid fixed-term contracts for three months each, which Sampana requested.
- Complaints were received about Sampana's teaching manner, prompting non-renewal of contract.
- TMTCP denied illegal dismissal and retirement pay, excluding consultant period from service computation and denying 14th month pay as a management prerogative.
Labor Arbiter’s Ruling (August 31, 2017)
- Sampana was found a regular employee under Article 280 of the Labor Code having served at least one year continuously or broken from March 2011 to December 2016.
- He was entitled to retirement pay computed at PHP 116,775.00.
- Other claims such as 14th month pay and training fees were denied.
- Illegal dismissal claim was dismissed as Sampana opted to retire.
National Labor Relations Commission (NLRC) Decision (June 26, 2018)
- Reversed labor arbiter on retirement benefits, holding Sampana was not a regular employee but a fixed-term employee from March 21, 2014 to December 21, 2016.
- Consultant period from 2011 to 2014 excluded from computation since no employer-employee relationship existed.
- Sampana failed to meet five-year service requirement for optional retirement benefits.
- Motion for reconsideration denied.
Court of Appeals (CA) Decision (March 18, 2021)
- Affirmed NLRC ruling that Sampana was a fixed-term employee by agreement and no employer-employee relationship existed during consultancy period.
- Noted that Sampana voluntarily agreed to 3-month contracts, which were uniformly renewed but valid.
- Determined no evidence of force, duress or vitiated consent in contract renewal.
- Confirmed Sampana’s failure to meet five-year service requirement for retirement.
- Denied illegal dismissal claim on ground of contract expiration.
Petitioner's Arguments in the Present Petition
- Claimed regular employment status due to continuous service spanning over five years under unilaterally prepared contracts by TMTCP.
- Contended fixed-term piecemeal contracts were designed to circumvent security of tenure.
- Asserted right to optional retirement benefits given tenure and age.
TMTCP’s Opposition
- Petition raised factual questions not reviewable under Rule 45.
- Reiterated validity of fixed-term contracts and denied entitlement to retirement benefits.
Issues Presented
- Whether Sampana is a regular employee of TMTCP.
- Whether Sampana’s dismissal was illegal.
- Whether Sampana is entitled to backwages and retirement benefits.